Apple Inc. v. Samsung Electronics Co., Ltd. et al
Declaration of Heather H. Martin in Support of #142 Opposition/Response to Motion, filed byGoogle Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14)(Related document(s) #142 ) (Candido, Amy) (Filed on 4/28/2012)
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June 7, 2011
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Weil, Gotshal & Manges LLP
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Certain Mobile Devices and Related Software, Inv. No. 337-TA-750 (U.S.I.T.C.)
Dear Mr. Jou:
I write to follow up on my letter of June 3 and our meet-and-confer discussion of earlier today
regarding the production of documents and source code by non-party Google Inc. (“Google”).
Additional Source Code Protections
During our discussion, we agreed to submit a joint motion to amend the protective order
regarding production of documents and source code by Google, including the additional
protections in my letter of June 3. As you requested, I have enclosed with this letter a Word
version of my June 3 letter, so that you can prepare a revised draft motion. We look forward to
reviewing this draft.
Google’s Document and Source Code Production
We also discussed Google’s production of documents in response to Apple’s subpoena in this
investigation. Google has begun the search and review process for this production, and
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June 7, 2011
anticipates producing responsive and non-privileged documents before the end of June.
Regarding source code, we confirmed that in this investigation Apple seeks only Android
operating system files for builds corresponding to the two accused Motorola lead devices: the
Motorola Droid and Xoom. Google will make this code available for inspection on a
confidential source code computer as soon as possible following entry of an appropriate
Google 30(b)(6) Depositions
Finally, we discussed scheduling depositions of Google’s corporate designees in response to
Apple’s subpoena. Google will provide witnesses as soon as possible and will attempt to provide
witnesses in June but, given the timing of the subpoena, may not be able to do so. In that case,
we agreed to discuss a potential motion to extend the discovery deadline for the purpose of
deposing Google’s corporate designees.
Please let me know if you disagree with any of the foregoing.
Very truly yours,
Matthew S. Warren
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